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Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
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Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
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Water Supply Protection
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Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
State
CO
Date
2/18/2003
Author
Porzak, Glenn E.; Bushong, Steven J.
Title
Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
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Court Documents
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16, 2000). As Vail's sole water provider, the District agreed to adjudicate, maintain, and <br />administer the Park's water rights. (v.X, p.60,1.18 -23). Obtaining these water rights is critical to <br />protect the flows that are essential to' the Park's success. (Id.). <br />Northern has asserted that the District does not have the legal authority to appropriate <br />recreational in- channel water rights. The Water Court disagreed, stating that the Special District <br />Act, C.R.S. §§ 32 -1 -101 to -1605 (2002), conferred "direct statutory authority" upon the District <br />"to acquire recreational ... water rights for customers within its service area, including the Town <br />of Vail" and that the District has "independent statutory authority to enter into agreements with <br />and for the benefit of customers within its service area." See Decree at 3 -4. The law and facts <br />supporting the Water Court's decision are summarized below. <br />1. The Colorado Constitution and the 1969 Act Provide Broad Authority to the <br />District to Appropriate Water Rights <br />The Colorado Constitution provides the undeniable right to divert the unappropriated <br />waters of the State to beneficial use. See Colo. Const. Art. XVI, § 6. This is one of Colorado <br />water law's bedrocks and its application has never been limited by the courts to an exclusive <br />class of appropriators; the law explicitly provides the opposite. Under the 1969 Act, " a n <br />person who desires a determination of a water right ... shall file with the water clerk ... a <br />verified application." § 37- 92- 302(1)(a) (emphasis added). "A person" is "an individual, a <br />partnership, a corporation, a municipality, the state of Colorado, the United States, or any other <br />legal entity, public or private." § 37 -92- 103(8). <br />The District clearly falls within the purview of this very broad, inclusive definition of those <br />that may seek water rights. The District is a water and sanitation district, which is a type of <br />special district. (v.X, p.77,1.16 -20); § 32- 1- 103(24). Special districts, in turn, are quasi- <br />Sb1549 -25- <br />
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